APPENDIX A
 

Public and Agency Comments and Forest Service Responses
 
 

 

United States Department of the Interior
 

OFFICE OF THE SECRETARY
 

Office of Environmental Policy and Compliance
 

620 SW Main Street, Suite 201
 

Portland, Oregon 97205-3026
 

9043.1 

IN REPLY REFER TO 

ER12/788 

Electronically Filed 

December 7, 2012 

Jerry Ingersoll 

Forest Supervisor 

Siuslaw National Forest 

855 Highway 101 

Reedsport, OR 97467 

Dear Mr. Ingersoll: 

The Department of the Interior has reviewed the Draft Environmental Impact Statement for the 

Oregon Dunes NRA Management Area 10(C) Designated Routes Project. The Department does 

not have any comments to offer. 

We appreciate the opportunity to comment. 

Sincerely, 

Allison O’Brien 

Regional Environmental Officer 

Page 1
Roxana Grant, MBA 

Executive Director 

Downtown Roseburg Association 

912 SE Washington Avenue 

Roseburg, OR 97470 

USPS 

Michele Holman Jones 

District Ranger 

Central Coast Ranger District/Oregon Dunes NRA 

Siuslaw National Forest 

Waldport, OR Cf?391­

I write this letter in opposition to the closures proposed for the Douglas County Dunes . 

We here in the Downtown Roseburg Association are trying to keep business alive and well in our 

Downtown area . 

The proposed closure in Douglas County would have a huge impact on some of our Downtown 

businesses. This type of impact has far reaching economic downside. As you well know any change that 

causes a hardship in one area that is interdependent on another cause a domino effect. Local business 

would be affected. 

When the Congress gifted the lands for recreational use, I am sure they did not mean for it to be given and 

then taken away. I base this on the "minimization" by previous NEPA decisions . Ie: 1970 ODRNA 

Management Plan, reduction by approx 47%, down to 15000 acres . 1994 ODRNA Management Plan 

adoption another reduction of 5930 acres. The 10 (C) zoning creates an illusion that 4455 acres of 

designated routes are available for OHV use, reality is only 10 miles of designated routes exist in Zone 10 

(C) that acreage is reduced to less than 1 acre(actualland footprint of the routes). Between 1972 and 

2011 the acreage available for riding has been reduced from 28000 acres down to just below 6000 acres . 

20% of the NRA is available for legal OHV use today. (BRC 20 13) 

Riding areas are disappearing faster than they are being created. 

As the Executive Director of the DRA I am opposed to this closure of riding areas , as the impact will be 

more far reaching than just the dunes and the riders . 

fully, 

Executive Director 

Downtown Roseburg Association 

Page 2
BOARD OF COMMISSIONERS 


DOUG ROBERTSON JOSEPH LAURANCE SUSAN MORGAN 

1036 S .E. Douglas Ave., Room 217 • Roseburg, Oregon 97470 • (541) 440-4201 

January 18, 2013 

Angie Morris, Recreation Planner 

Siuslaw National Forest 

855 Highway 101 

Reedsport, OR 97467 

RE: Oregon Dunes NRA Management Area 10(C) Designated Routes Project Draft Environmental 

Impact Statement Coos, Douglas and Lane Counties, Oregon 

Dear Ms. Morris: 

The Board of County Commissioners for Douglas County appreciates this opportunity to provide 

comments on the Draft Environmental Impact Statement ("Draft EIS") on the "Oregon Dunes NRA 

Management Area lO(C) Designated Routes Project. The Oregon Dunes NRA is an important social, 

economic, recreational and biological resource of the local community and Douglas County. 

The Board has reviewed the Draft EIS and submits the attached comments for your review. 

Whil e not specifically addressed in the purpose and need of the Draft EIS, the Board wishes to also direct 

your attention to Section 12 of the Oregon Dunes National Recreation Area Act (P.L. 92-260) wherein the 

Secretary was to establish an advisory council : 

"The Secretary shall establish an advisory council for the Oregon Dunes National Recreation Area, 

and shall consult on a periodic and regular basis with such council with respect to matters 

relating to management and development of the recreation area. The members of the advisory 

council, who shall not exceed fifteen in number, shall serve for individual staggered terms of 

three years each and shall be appointed by the Secretary as follows: 

(i) a member to represent each cou nty in which a portion of the recreation area is 

located, each such appointee to be designated by the respective governing body of the 

county involved ...." id. at Section 10 (16 U.S.C. §460z-10). 

The Board of Commissioners request that as a sepa rate nondiscretionary action, the Secretary establish 

t he advisory committee. In the absence of the Section 10 committee, the Forest Service is arbitrarily 

avoiding the consultation requirements, and benefits, of the Act. 

Page 3
We appreciate your discussion providing history relative to the time constraints and process required in 

implementing the original mandate to appoint members to an advisory council per P.L. 92-260. Further, 

we r ecognize and appreciate that an ad-hoc committee (OHV Designated Routes Working Group) was 

established to advise on the transportation issues that are the subject of the Draft EIS. The efforts of 

this working group are appreciated and were clearly invaluable to the Forest Service in preparing this 

proposed action. We nonetheless urge you to either appoint the P.L. 92 -260 advisory committee, or, in 

the alternative, continue the advisory working group on a permanent basis. We feel strongly that an ongoing advisory group will positively inform the management discussion related to the recreation area, 

especially during the implementation phase of this pr oject. It wi ll also provide a forum for the recreating 

citizens and Siuslaw National Forest to share information, discuss issues and reach consensus. Douglas 

County requests that the commi ttee include two members which are appointed by the Board of County 

Commissioners of Douglas County. As you initiate the new planning process in 2014, the advisory 

committee would be invaluable in helping to define the scope of the analysis, identifying relevant issues, 

and, in assisting in development of alternatives. 

A second issue that is not necessarily part of the purpose and need but one that we believe should be 

addressed at this time, is the Dune restoration, specifically control of the beach grass (e.g. Amophila 

arenaria) that originated with artificial plantings. The control of this vegetation was a focus of the 

origina l Act and one we believe can be partially addressed through the management of off-road vehicle 

use. We understand that the special off-road vehicle ad hoc committee raised this issue and 

recommended that this be a separate alternative. We, likewise, recommend that this recommendation 

be incorporated into the final plan. 

Further, it is important to recognize that access to the recreational opportunities within the Oregon 

Dunes NRA is a critical element and foundation of the economy of the Winchester Bay- Reedsport area 

and Douglas County as a whole. Over the years, as fishing and loggin g have been adverse ly impacted, 

ATV riding has increased in economic importance. Maintaining a diversity of ridin g opportunities is a 

critical aspect of providing the recreational opportunities envisioned when the Oregon Dunes NRA was 

enacted. 

It is also important that whatever option you select maintain the diversity of recreational riding 

opportunities. Therefore we request that the recreation opportunities on the upland (forested) portion 

of the Middle Riding Area be open subject only to limitations necessary to address safety issues. 

The Board of Commissioners appreciates this opportunity to submit the attached comments. Based on 

the current proposed alternatives, the Board supports the adoption of Alternative 5 as it is the most 

consistent with the plans and policies of Douglas County. 

Page 4
ATTACHMENT A 


COMMENTS OF THE DOUGLAS COUNTY BOARD OF COUNTY COMMISSIONERS 


On the 


OREGON DUNES NRA MANAGEMENT AREA 10(C) DESIGNATED ROUTES PROJECT 

DRAFT ENVIRONMENTAL IMPACT STATEMENT. 

1. The legislative History at the time the Oregon Dunes NRA was created, clearly demonstrates 

Congress' intent that the area be administered to provide for public recreation use and enjoyment. 

Conservation of scenic, scientific, historic, and other values contributing to such enjoyment was in the 

context of providing for this recreation use and enjoyment. The management of and the designation of, 

MA 10(C) and MA 10(8} trails must be in the context of the original Act. 

2. Douglas County notes that when the relationship between vegetation management and 

transportation was raised in the original Act, the Legislative History referenced that the guiding principle 

was that in the more developed areas the Forest Service was to maintain native vegetation and avoid 

alteration through clearing for roads and facilities and through adequate control of public use. likewise, 

in undeveloped areas vegetation management was to be used in order to avoid damage in the fragile 

pioneering plant communities - the intent was that use restrictions were to be applied in order to 

protect these fragile pioneering communities, not generically across the landscape. The legislative 

History was clear when Congress noted that the lack of vegetation in some areas is a definite 

recreational asset and that artificial plantings of sand-stabilizing plants are a detriment. 

In the development of the MA 10(C) strategies, the Forest Service has ignored that Congress was not 

expressing a concern about ATV use on all vegetated areas, rather the concerns were in the context of 

the three issues referenced -namely maintain native vegetation, avoid alteration through clearing for 

roads and facilities, and, adequate control of public use. It was with these concepts in mind that 

Congress referenced the need for a buffer of vegetated, undeveloped land be maintained between the 

active dunes and developed property- not maintenance of all vegetative areas. Douglas County is of 

the opinion that the concern over ATV use along historic pioneered roads within the vegetative areas 

must be considered in the original context. Since the Draft EA discussion relative to the impact of ATV 

use on vegetated trails does not distinguish between (a) vegetative buffers for developed facilities, (b) 

damage to fragile pioneering plant communities, or, (c) the benefit of buffers between active dunes and 

improved property, the proposed actions are inconsistent with the Act. It is only those historic and 

cultural routes that are inconsistent with this three part test that should be closed in the MA 10(C) 

context. Trails that do not fall within this category should be designated for access to the beach. 

3. In assessing which roads are necessary for closure based on concerns over vegetation, the Forest 

Service must recognize that Congress clearly envisioned that additional roads and recreational facilities 

would become necessary in the future. Congress specifically noted that vegetation would need to be 

removed in places for construction of these facilities and, that in doing so, adequate controls would be 

established that accommodated these additions as well as avoided adverse impacts. The proposed 

action does not consider the question of whether these routes through the MA 10(C) areas are 

Page 5
consistent with Congress' recognition that additional roads and facilities would be necessary- nor does 

it consider how other forms of control measures and management techniques would allow these routes 

to be left open while meeting the objectives of Congress. The goal of minimizing impacts must be read in 

the context of the entire legislation not just the MA 10(C) goals. 

4. Douglas County agrees with the Forest Service that historic routes that connect sand camping 

areas and private/state/county in-holdings to the open riding areas be classified as open for ATV use. 

5. The Oregon Dunes NRA is one of the major economic driving forces within coastal Douglas 

County. Congress recognized the economic value of the NRA and expressly noted that the designation 

would increase recreational use and in turn increase recreational expenditures. This was one of the 

original guiding principles underlying the Act. Congress expected the NRA would increase from the preAct usage levels to 4.3 million visitor days by 2000. Further, it anticipated another 5 million visitor days 

of use will probably occur on lands and waters adjacent to the NRA. These combined uses were 

expected to generate about $54 million annually. The Forest Service, however, reports in its economics 

analysis that usage is only 1.1 million visitor days (of which OHV use is considered to be 650,000) and 

that the economic contributions are substantially lower at $2.5 million for OHV use. In assessing the 

proposed impact of the closing of roads and trails in the MA 10(C) areas, the Forest Service needs to 

closely examine why the projected increases did not occur; whether closing these historic trails will 

reduce any of the recreational uses; and, examine whether leaving them open will lead to increases in 

the user numbers and economic impacts. There is a significant disconnect with the 4.3 million visitor 

days that were anticipated to occur between 1972 and 2000 versus what is actually occurring. The goal 

of minimizing impacts must be read in the context of the entire legislation. Since there is a significant 

disparity between the Act's anticipated economic outputs and the actual outputs, the Forest Service 

should reexamine the economics with a methodology that actually examines the differences rather than 

assume no ability to distinguish between alternatives. 

6. It is difficult to ascertain from the Draft EIS whether the risk assessment relative to introduction 

of the various invasive species is driven by the introduced beach grass or other species. While there is 

variation between the various alternatives, it is difficult to ascertain what species are driving the 

comparisons. It is notable that while the risk is attributed to be high under some alternatives, the Forest 

Service nonetheless concludes that continuation of the user-developed historic trails is not considered 

to have an effe~ on the current extent of native vegetation in the project areas. It is questionable 

whether invasive species risk is in fact a true driving issue that allows separation between the 

alternatives. Further, based on Douglas County's experience in the management of invasive aquatic 

species, a management technique that can greatly aid in reducing invasive species is the installation of 

vehicle washing facilities. In this case, washing facilities at public and private campgrounds and trail 

heads would be one effective tool that would reduce the risk across all alternatives. 

7. Douglas County is concerned that the spread of vegetation into areas that were once open sand 

is a new circumstance that justifies redesignating these vegetated trails as MA 10(8) open riding. The 

historic photographs presented by Gary Leif provide an excellent graphic display of how the current 

management is not addressing the vegetation changes. The vegetation is clearly intruding on areas that 

were open sand riding areas at the time the Act was adopted. Further, your proposal to close trails that 

are in areas that were open sand in the 1970's is inconsistent with the legislative history accompanying 

the Act. 

Page 6
8. Notwithstanding that the purpose and need is in the context of transportation, the underlying 

issue is vegetation management. Given that beach grass is a driving force in the changing plant 

communities and the rider access, the impacts of beach grass encroachment on transportation/rider 

access and strategies to control beach grass should be addressed as environmental impacts as well as 

connected and cumulative actions. 

9. Measuring rider safety solely in the context of injuries reported to medical facilities is one way to 

monitor safety; however, there are other more sensitive ways to measure rider safety that would allow 

comparison between alternatives. For example, the interaction rate between riders would be a reliable 

measure of safety- namely the less interaction the less likely for rider to rider accidents. Further, the 

Douglas County Sheriff has indicated that there is statistical data that tracks injuries to OHV riders within 

the riding areas. We recommend that the ROD and final EIS incorporate this information which is 

available through the local law enforcement agencies. We suggest the Forest Service reexamine the 

rider safety issue in both of these contexts. 

10. All alternatives should be explored in the context of minimizing management and enforcement 

costs. If the selected alternative cannot be logically, economically or practically enforced, then it does 

not achieve the goals ofthe Oregon Dunes NRA. 

11. The final decision should recognize the historic overlook areas on the western side of Clear Lake 

in the Middle Riding Area. These areas should be classified as designated open trails under 10(C) and 

maintained in their historic primitive riding condition. 

12. In the Middle Riding Area, the connecting trails at Banshee Hill and to the immediate south 

thereof should be classified as either 10(8) areas or as 10(C} designated as open areas. 

Page 7
Bruce Hanna 

January 22, 2013 State Representative, District 7 

Mr. Jerry Ingersoll 

c/o Angie Morris, Recreation Planner 

Siuslaw National Forest 

855 Highway 101 

Reedsport, OR 97467 

Re: Response to Draft EIS Area 10(c) Designated Routes Project 

Mr. Ingersoll: 

With respect, I write today to oppose the proposed options presented in the Forest Service's Draft EIS 

regard ing the Oregon Dunes National Recreation Area (ODNRA) 10c designated routes project. As a 

lifelong resident of Douglas County, the sitting State Representative for rural Douglas and Lane Counties, 

and an avid outdoor enthusiast, I find this proposal both frustrating and flawed. 

In 1972; Congress established the ODNRA, recognizing that Oregon's landscape provides unique 

recreational opportunities for families. Of the 28,900 acres originally dedicated to this area, more than 

half have now been closed to OHV use. The current DEIS runs counter to the intent of Congress when it 

established the ODNRA as a primarily open riding area "to provide for the public outdoor recreation use 

and enjoyment." This intent rings true today, but this proposal runs counter to it. 

Further, the proposal places additional, cumbersome restrictions on already regulated use of land 

nationally recognized as a destination for outdoor recreation. I urge you to consider the economic 

impact of this proposal. OHV activity in the Dunes is a $270 million industry. Further restrictions will only 

serve to reduce that number, the impact of which could be enormous in a part of the nation already 

experiencing severe economic depression. 

Safety and environmental concerns in the ODNRA are of <;:Qurse critical. I remain committed to ensuring 

Oregonians and visitors to our great start are both safe and have a destination to visit for generations to 

come. However, it is unclear how the decision to further restrict acreage in the proposed 10c 

designation will really accomplish these goals without causing even greater harm in the coastal 

communities of Coos, Douglas and Lane Counties. 

In the future, I hope there is greater coordination between the USFS and local communities in 

identifying appropriate and effective solutions. 

Sincerely, 

Bruce 

~~ Hanna 

State Representative, District 7 

Page 8

900 Court St. NE, Salem, OR 9730 1 

Phone: (503) 986-1407 
Jf 

ROSEBURG 

AREAChamber of 

Commerce 

410 51 Spruce Street 

P.O. Box 1026 

Roseburg,OR 97470 

Phone 541.672.2648 

: Fax 541.673.7868 ! 

! www.RoseburgAreaChamber.org 

January 16, 2013 

Ms. Angie Morris, Recreational Planner 

Oregon Dunes National Recreation Area 

Siuslaw National Forest 

855 Highway 101 

Reedsport, OR 97467 

R~: Oregon Dunes NRA Management Area 10(C) Designated Routes Project I Draft EIS 

Dear Ms. Morris: 

On behalf of the Roseburg Area Chamber of Commerce (RACC) and the 600 Douglas County businesses we 

represent, please accept this letter opposing the proposed options presented in the USFS Draft Environmental 

Impact Study (DEIS) on the Oregon Dunes National Recreation Area (ODRNA) 10c Designated Routes Project. 

The RACC believes the DEIS and related process is flawed on several points, not the least of which was failure 

to coordinate with affected counties (Douglas, Coos and Lane) and the apparent lack of consideration of the 

legislative intent of the National Recreation Area Act-to manage for OHV access and recreational use. At a 

I minimum, the RACC respectfully requests the DEIS be withdrawn and that the USFS conduct and issue a 

, supplemental EIS seeking additional input and including better alternatives than those presented in the I current DEIS. 

I The RACC certainly has a concern regarding the public safety issues related to the options proposed in the 

DEIS, as expressed by local law enforcement officials. However, as an organization focused on economic 

viability and job growth in our region, we have an even greater concern of the significant and adverse 

economic impacts current DEIS proposals would have on Oregon's coastal communities in Douglas, Coos and 

Lane counties . 

Thank you for your consideration. 

Best regards, 

MBER OF COMMERCE 

Debra L. Fromdahl, 10M 

President & CEO 

cc: The Honorable Jeff Kruse 

The Honorable Floyd Prozanski 

The Honorable Tim Freeman 

The Honorable Bruce Hanna 

The Honorable Wayne Krieger 

The Honorable Jeff Merkley 

The Honorable Ron Wyden 

The Honorable Peter DeFazio 

VISION To advocate for and be the voice ofthe business community in the greater Roseburg area. 

MISSION To strengthen, enhance and protect our members through political advocacy, economic development, community promotion and member programs and services. 

RO .EBURG AREA CH 

~LJL/ 

Page 9
WINCHESTER BAY MERCHANTS ASSOCIATION, INC. 

A Nonprofit Public Benefit Corporation 

P. 0. Box 1143 

Winchester Bay, Oregon 97467 

wbmerchants@yahoo.com 

Phone/Fax 541-271-4471 

December 31, 2012 

Angie Morris, Recreational Planner 

ODNRA 

855 Highway #1 01 

Reedsport, OR 97467 

Re: 	 Draft Environmental Impact Statement NRA Dunes 

10 (C) Area 

Dear Ms Morris; 

The Winchester Bay Merchants is a non-profit group made up of 

businesses and residents of Winchester Bay. We sponsor summertime 

festivals and more than any other group, speak for the merchants in the 

Winchester Bay area. 

In your recent SOPA for the area, you have offered five different 

alternatives for use a system of designated trails and open area riding. 

This letter is written in support of the least restrictive plan being 

offered and we would not object to a reconsideration of an additional 

alternative which would open up more area. The WBM worked closely 

with the reorganizational planning for the consolidation of the 

ownership of the land some years back so there would be less 

governmental agencies making conflicting and competing decisions on 

how OHV could best use the land area. One of the considerations that 

does not seem to be adequately explored is the changing nature of the 

environment with the lessening.of the inundation plain. It would seem, 

and there have been statements made, that within 25 years the "sand 

dunes" will have many times the vegetation that it has now. Your plans 

Page 10
should reflect this condition and make determinations that while nature 

does have a natural pattern which involves change, much of the 

reasons for the expected changes are manmade and work against the 

continued recreational use of the area with OHV. 

Please recognize the recreational use of the sand by ATV and sandrail 

owners is one of the "industries" that economically supports our 

community and has a minimal adverse effect on the environment. As 

to the illogic of: because there has been no lessening of recreational 

users to the area, our decisions have not been adverse to the economy. 

OHV users are growing at a fast rate, land available for such uses are 

decreasing. Without a " control site" your statement that there has not 

been an adverse impact is not supported. I would also suggest that you 

review the alcohol ban Q&A on your website and not continue to 

advance the statement that there was a " scoping" to obtain 

information. Here is your Q&A on that one: 

How was the public involvedin this decision? Can I comment 

on this? 

Yes, you may comment on the decision to issue this order. 

However, it is issued under the Forest Supervisor's 

administrative authorities for the purpose of addressing · a 

serious public and employee health and safety risk. Therefore, it 

is not subject to the same public involvement provisions as 

Forest Service project planning decisions, nor is public comment 

likely to affect change retraction of this order. 

The WBM held the st and only public meeting on the imminent order 

and tried to spre Cl the word. 

Should you ave any questions please feel free to contact us. 

Page 11
.. J 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 10 

. 1200 Sixth Avenue, Suite 900 

Seattle, WA 98101-3140 

December 7, 2012 · 

OFFICE OF 

ECOSYSTEMS, TR IBAL AND 

PUBLIC AFFAIRS 

Angie Morris, Recreation Planner 

Siuslaw National Forest 

855 Highway 101 

Reedsport, Oregon 97467 

Re: 	 EPA Region fO Comments on the on the Draft Environmental Impact Statement (DEIS) for the 

Oregon Dunes NRA Management Area (EPA Project #93-013-AFS) 

Dear Ms. Morris: 

We have reviewed the DEIS for the Oregon Dunes National Recreation Area (ODNRA) Management 

Area (MA) 10(c) Route and Area Designation on the Siuslaw National Forest in Oregon. We are 

submitting the following comments in accordance with our responsibilities under the National 

Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act (CAA). 

Section 309 of the CAA specifically directs the U.S. Environmental Protection Agency (EPA) to review 

and comment in writing on the environmental impacts associated with all major federal actions. Our 

review of the DEIS considers the expected environmental impacts, and the adequacy of the EIS in 

meeting procedural and public disclosure requirements of NEPA. 

The DEIS analyzes a no action alternative and four action alternatives. The action alternatives consider 

variations in the number of miles of designated riding routes and areas designated for open riding. The 

preferred alternative (Alternative 4) would designate 2.1 miles of routes and reallocate 455 acres from 

MA 	10(C) (Off Road Vehicles on Designated Routes) to MA 10 (B) Off-Road Vehicle Open. This 

alternative would also close approximately 84 miles of user-developed routes. 

In our July 2011 scoping comments we indicated support for the proposed action (Alternative 2). 

Relative to ~lternative 2, the preferred alternative (Alternative 4) reallocates an additional 221 acres to 

MA 10 (B) and closes 18 fewer user-developed routes. We support the proposed closure of unauthorized 

routes under Alternative 4, but we encourage the Forest to consider bringing forth elements from 

Alternatives 2 and 3 as the final preferred alternative is developed. 

In particular, we notethat the reallocation of areas A4 and portions of A16 under Alternative 4 would 

result in high impacts to native plant associations (Table 29) . We also note that area A16 still has many 

intact portions of native vegetation and likely still supports use by nesting, migrating and wintering 

birds. As noted on page 106 of the DEIS, the proposed change in management of this area to MA 10 (B) 

would likely cause further degradation of native vegetation, making this area less suitable for land birds. 

Given these potential impacts we make the following recommendations: 

Page 12
2 

1) Revise management direction for area A4 to avoid impact to areas where shore pine/slough 

'sedge associations are present; or pursue the management strategy under Alternative 3 for this 

area. 

2) Revise management direction for area Al6 to avoid impact to the 19 percent of the. reallocation 

area that is mapped as native vegetation; or pursue the management strategy under Alternative 2 

for this area. · 

We also note that the risk of introducing or spreading invasive species via reallocations from MA 10 (C) 

to MA 10 (B) is "high" under Alternative 4 (Table 30). Control of invasive plant species is discussed 

under Project Design Criteria (DEIS p. 51), however detail is lacking. It is stated that invasive plant 

species would be controlled "by the most effec~ive means allowed." We recommend that the FEIS 

discuss manqgement triggers/thresholds and measures (herbicides, biological controls, mechanical 

removal, etc.) . 

If herbicides are to be used to control infestations, mitigation measures should be identified to avoid 

herbicide drift to streams and wetlands during ground and aerial applications. Measures might include 

the identification of streamside buffers, mechanical weed removal adjacent to streams, flagging aquatic 

areas on the ground, spray nozzles that produce larger droplets to reduce drift, use of photodegradable 

dyes in herbicides, use of GPS technology, use of spray detection cards, wind monitoring, herbicide 

monitoring, etc.). 

In addition, we believe that recommendation 2 above would substantially address the risk of invasive 

plant infestation by reduCing the number of acres under MA 10 (B) . 

Due to our concerns over native plant associations, bird habitat and invasive species, we have rated the 

proposed alternative EC-1 (Environmental Concerns- Adequate). An explanation of this rating is 

attached. We appreciate the opportunity to provide comments, and we believe that the management plan 

will play an important role in establishing a more comprehensive and understandable system of 

designated routes for the ODNRA. Please contact me with any questions at (206) 553-1601 or by 

electronic mail at reichgott.christine@epa.gov, or you may contact Teresa Kubo of my staff at (503) 

326-2859 or kubo .teres a @epa.gov. · 

Sincerely, 

Christine B . Reichgott, Manager 

Environmental Review and Sediment Management Unit 

Page 13
LO- Lack of Ob.iections 

U.S. Environmental Protection Agency Rating System for 

Dt·aft Environmental Impact Statements 

Definitions and Follow-Up Action* 

Environmental Impact of the Action 

The U.S. Environmental Protection A.gency (EPA) review has not identified any potential environmental impacts . 

requiring substantive changes to the proposal. The review may have disclosed opportunities for application of mitigation 

measures that could be accomplished with no more than minor changes to the proposal. 

EC- Environmental Concems 

EPA revie'-v has identified environmental impacts that should be avoided in order to fully protect the environment. 

Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce 

these impacts. 

EO- Environmental ObJections 

EPA revievv has identified significant environmental impacts that should be avoided in order to provide adequate 

protection for the environment. Corre.::tive meas Jres may require substunti:~[ changes to the preferred a!ter!lative or 

consideration ofsome other project alternative (including the no-action alternative or a new alternative). EPA intends to work 

with the lead agency to reduce these impacts. 

Elf- Envit·onmentally Unsatisfactot·y 

EPA review has identified adverse environmental impacts that are. of sufficient magnitude that they are unsatisfactot)' 

from the standpoint of public health or welfare or environmental quality. EPA intends to work with the lead agency to reduce 

these impacts. Ifthe potential unsatisfactory impacts are not corrected at the tina! EIS stage, this proposal will be 

recommended for referral to the Council on Environmental Quality (CEQ). 

Adequacy of the Impact Statement 

Category 1 -Adequate . 

EPA believes the dratt EIS adequately sets forth the environmental impact(s) of the preferred alternative and those of the 

alternatives reasonably available to the prqject or action. No further analysis of data collection is necessary, but the reviewer 

may suggest the ·addition of claritying language or information. 

Category 2- Insufficient Information 

The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be 

avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives that 

are within the spectrum of alternatives analyzed in the draft EIS, which could reduce the environrnental impacts of the action. · 

The identified additional information, data. analyses or discussion should be included in the final EIS. 

Category 3 -Inadequate 

EPA. does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the action, or 

the EPA reviewer has identified new, reasonably available alternatives that are outside of the spectrum of alternatives analyzed 

in the draft EIS, which should be analyzed in order to reduce the potentially significant environmental impacts. EPA believes 

that the identified additional information, data, analyses, or discussions are ofsuch a magnitude that they should have full 

public review at a draft stage. EPA docs not believe that the draft EIS is adequate for the purposes ofthe National 

Environmental Policy Act and or Section 309 review, and thus should be formally revised and made available for public 

comment in a supplemental or revised draft EIS. On the basis ofthe potential significant impacts involved , this proposal could 

be a candidate tor referral to the CEQ. 

* From EPA 1\-fanual 1640 Policv and Procedures for the Review of Federal Actions Impacting the Environment. February , 

1987. 

Page 14
December 7, 2012 

TO: Angie Morris, Recreational Planner 

USDA Forest Service 

FROM: John Hanlin, Douglas County Sheriff; Craig Zanni, Coos County 

~~ 

· ·· i~ heriff John Hanlin Sheriff Craig Zanni Sheriff Tom Turner 

Douglas County Coos County Lane County 

Sheriff; Tom Turner, Lane County Sheriff 

SUBJECT: 	 Oregon Dunes NRA Management Area 10 (C) Designated Routes 

Project, Draft Environmental Impact Statement 

This letter is in response to the Draft Environmental Impact Statement for the 

Oregon Dunes National Recreation Area (ODNRA) Management Area 10 

Designated Routes Project. It is our understanding that we are entering the final 

phase of the 1 OC process and we have several concerns. Closure of riding 

areas under this plan would impact areas in Coos, Douglas, and Lane Counties . 

As chief law enforcement officers of our counties, entrusted to make public safety 

decisions that are in the best interest of those we serve, we feel our concerns 

and input involving the closure of public lands should be heard and considered in 

this planning process. We have yet to be contacted and involved in any 

discussions or planning relating to the ODNRA Management Area 10 (C) 

Designated Routes Project. 

There are substantial economic impacts that would occur, but more importantly 

are the public safety threats that additional riding area closures would create . 

Contrary to the information on page 14 of the DEIS, there are sufficient statistics 

available to track injuries to OHV riders within the riding areas at the ODNRA. 

These statistics are tracked and available through local law enforcement 

agencies and the Oregon Department of Motor Vehicles. The information 

contained under "Rider Safety" (pg. 14) of the DEIS is incomplete and inaccurate. 

There are many public safety issues that need to be accurately shared and 

discussed. As a cooperating agency we request the opportunity to be involved in 

coordinated planning of any closures of the ODNRA. We would further request 

that an extension to the review period be implemented to allow for this 

coordinated process. 

Respectfully, 

Page 15
LANE COUNTY BOARD OF COMMISSIONERS 

Jay Bozievich 

Rob Handy 

Sid Leiken 

Pete Sorenson 

Faye Hills Stewart 

December 5, 2012 

Ms. Angela Morris, Recreation Planner 

United States Forest Service 

Siuslaw National Forest 

3200 SW Jefferson Way 

Corvallis OR 97331 

Dear Ms. Morris: 

The Lane County Board of Commissioners submits the following comment with respect to. 

the "1 OC Designated Routes Project #34220". These comments were approved by our full 

Board of County Commissioners during their regularly scheduled meeting of December 11, 

2012 . Please note that Lane County previously provided comment on this issue to your 

office through correspondence dated August 18, 2011. 

1) Lane County feels very strongly the congressionally mandated Advisory Committee 

must be reconstituted. We have previously noted that the Forest Service appears to be 

out of compliance with the Oregon Dunes National Recreation Act of 1972 (PL 92-260, 

Section 12(a)). Within our own organization we regularly and formally create and 

recognize advisory committees to guide our, and our Department's , actions. It is our 

expectation that the Forest Service follow what is clearly provided for in law with respect 

to this Advisory Committee. 

2) 	 Related to comment 1 is that Federal law is quite clear with respect to consulting with 

Lane County in its role as a cooperating agency. In fact, while we are pleased that the 

comment period for this plan was extended, we were not formally alerted to this 

opportunity by the USFS , and only learned of it through the communications of our 

concerned citizenry. 

3) 	 We question the finding that non-designated routes within the MA 10 (C) areas have 

created " .. . greater and unnecessary impacts to important plant communities .. ".; This 

finding appears to conflict with other statements indicating the prevalence of non-native, 

invasive vegetation such as European beachgrass and Scotch broom within MA 10 (C). 

We would urge a finding that continues to recognize the full 4,455 acres within that area 

be designated Open Riding 10 (B). 

4) 	 The economic analysis provided as part of the USFS Draft Environmental Impact 

Statement analysis is severely flawed . The finding of no economic impact must not 

remain in the final EIS, and we would ask that your office examine the analysis provided 

by Oregon State University on the economic benefit to Lane, Douglas, and Coos 

Counties provided by OHV users and visitors (many of whom travel here from Canada). 

This analysis shows $86M of economic impact. The USFS finding of $2.5M per year is 

without merit. 

y Commissioner 

Page 16

PUBLIC SERVICE BUILDING /125 EAST 8TH AVENUE I EUGENE , OR 97401/ (541) 682-4203/ FAX (541) 682-4616 
Florence Area Chamber of Commerce 


290 Hwy 101 


Florence OR 


January 22, 20 13 

Re: Oregon Dunes NRA Management Area I O(c) 

Designated Routes Project/Draft EIS 

Ms. Angie Morris, Recreational Planner 

Oregon Dunes National Recreation Area 

Siuslaw National Forest 

855 Hwy 101 

Reedsport OR 97467 

Dear Ms. Morris, 

The Florence Area Chamber ofCommerce is opposed to the USFS proposed closure options as contained in the current 

draft environ me nta l impact study on the ODRNA IOc Designated Routes Project. We feel there are many inaccurate 

findings regarding the economic impact on the proposed c losures contained in the study: out of a 152 page document that 

allegedly addresses the overall impacts, w ith on ly five pages, (14, 15, 137, 138 & 139) addressing economic impacts vs. 

the exhaustive detail of environmental impacts, the study ofthe economic impact is clearly not adequate. For example, 

the reference on page 137 that " ... ODNRA contributes about $2.5 million annually to the three counties within which the 

ODNRA is located (Coos, Douglas and Lane). It accounts for about 82 jobs within the three-county area" we feel is 

simply not accurate- there are probably in excess of 82 jobs alone just w ithin the Florence area that are directly related to 

the use of the dunes. 

While we a11 cherish and wish to preserve the Oregon National Dunes as it is in our own back yard, it is that fact as we11 

that makes it a tremendous resource for our economy a lso. Our membership is overwhelmingly opposed to these closures, 

for example, one comment from our survey: "One branch ofthe government or another since 1980 has closed down a 

logging industry , a sawmill industry, a fishing industry, and now they want to take the second step towards closing a 

thriving tourism industry." It is extremely critical at this point in the economic condition of our community that we not 

continue to impede our area economy. 

Thank you for your consideration. 

{?~ 

Cal 

Executive 

.App ~ Dire 

Cc: 	 Senator Arnie Roblan 

Representative Catheri ne McKeown 

Governor John Kitzhaber 

Senator Jeff Merkley 

Senator Ron Wyden 

Representative Peter DeFazio 

Page 17
BOARD OF COMMISSIONERS 


DOUG ROBERTSON JOSEPH LAURANCE SUSAN MORGAN 

1036 S.E. Douglas Ave., Room 217 • Roseburg, Oregon 97470 • (541) 4404201 

January 25, 2013 

Angie Morris, Recreation Planner 

Siuslaw National Forest 

855 Highway 101 

Reedsport, OR 97467 

RE: Oregon Dunes NRA Management Area 10(C) Designated Routes Project Draft 

Environmental Impact Statement Coos, Douglas and lane Counties, Oregon 

Dear Ms. Morris: 

The Board of County Commissioners for Douglas County recently subm itted comments on the Draft 

Environmental Impact Statement ("Draft EIS") on the "Oregon Dunes NRA Management Area 10(C) 

Designated Routes Project. It has recently been brought to our attention that a provision in the 

letter was not removed when new comments were added to the comment section. 

The very last paragraph contained the statement that between the various current proposed 

altern atives, the Board fo und Alternative 5 as it is the most cons istent with the plans and policies of 

Douglas County. It has come to our attention that this may be taken out of context. While 

Alternative 5 is the best fit among the proposed alternative s, the Board believes that none of the 

current alternati ves meet the objectives of the Act or the policies and plans of Douglas County. 

The Board believes that no act ion should be taken until the matters can be examined in a 

comprehensive planning process that reexamines the land management plan and the land 

allocations t herein. 

Respectfully subm itte d, 


DOUGLAS COUNTY BOARD OF COMMISSIONERS 


Page 18